Tag Archives: Compliance

By David Drake South Korea’s financial regulator has announced that the country will not allow trading of cryptocurrencies using anonymous accounts starting today, January 30th 2018. This means cryptocurrency traders won’t be able to make any deposits into their virtual wallets unless their cryptocurrency account details and the bank accounts they own match. One of the reasons why the cryptocurrency […]

The following article originally appeared in HFMWeek’s Cyber Compliance Focus. It’s not enough to have strong security policies. And it’s not enough to have robust technologies in place to ward off cyber threats. In truth, it’s not even enough to have both of these. An effective cybersecurity program, rather, can only be achieved through a consistent and comprehensive strategy that […]

February 3, 2016 Dear Friends, This morning the Wall Street Journal published an article on ” The Most Thankless Job on Wall Street” – compliance officer. According to the article, recent enforcement actions that have found compliance officers personally liable are driving experienced people to be more cautious about the profession – compliance officers say they feel unfairly singled out. […]

Dear Friends, FINRA suspended a registered representative for failure to disclose outside business activities, resulting in a $15,000 fine and a six month suspension from association with any FINRA member. The representative failed to disclose that he was a director and officer of a publicly traded company and the existence of an outside securities account in his name. Additionally, the […]

January 20, 2016 Dear Friends, The U.S. Supreme Court agreed to review a ruling of the U.S. Court of Appeals for the Ninth Circuit, which could clarify a key element of insider trading – what constitutes a personal benefit – resolving a dispute between divided federal courts of appeals. Second Circuit Decision: In December 2014, the U.S. Court of Appeals […]

January 11, 2016 Dear Friends, The SEC announced its examination priorities for 2016, as outlined below. Private Fund Advisers: The SEC’s examination of private fund advisers will focus on fees and expenses evaluating, among other things, the controls and disclosures associated with side-by-side management of performance-based and purely asset-based fee accounts. Never-Before-Examined Investment Advisers and Investment Companies: The SEC will […]

November 23, 2015 Dear Friends, Today, the SEC issued an order against an investment adviser for improper allocation of expenses to its fund client (the “Fund”) and failure to adopt compliance policies and procedures, specific to Fund expense allocation, resulting in a $250,000 settlement. The SEC found that the firm negligently charged compliance, legal and operating expenses to the Fund. […]

November 19, 2015 Dear Friends, Today the SEC announced that an investment adviser and its former CCO have agreed to settle charges that it repeatedly violated the custody rule. The Firm agreed to pay a $1 million penalty, to be suspended for one year from raising any capital, and to have a compliance monitor for three years. The former CCO […]

November 19, 2015 Dear Friends, The SEC has voted to propose new rules to enhance transparency and regulatory oversight of dark pools. Pursuant to the new rules, alternative trading systems (ATS) that trade stocks listed on a national securities exchange (NMS stocks), including dark pools, would be required to publicly disclose detailed information via the new form ATS-N, including: Information […]